Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Compass Culture and Education Ltd.  
Complaints Policy  
POLICY STATEMENT  
Compass Culture & Education Ltd recognises that students, parents, schools, staff, volunteers,  
homestays and other relevant parties may have concerns or complaints regarding our guardianship  
services. We encourage concerns to be raised promptly and respectfully, and aim to resolve them  
fairly, consistently and without disadvantage to anyone who complains in good faith. This policy sets  
out informal resolution, formal investigation and external referral to AEGIS.  
At Compass we:  
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Take all complaints seriously, listen to the complainant and consider the child’s welfare and views  
where relevant;  
Seek early, informal resolution where appropriate, while allowing serious concerns to be raised  
formally without completing the informal stage;  
Aim to provide a substantive written response to formal complaints within 28 working days;  
explain any necessary extension and give a revised date;  
Follow the staged procedure below and explain who will handle the complaint and how to request  
an escalation;  
Provide an outcome and any proportionate corrective action, whether or not the complaint is  
upheld;  
Arrange a fair investigation by someone who is not the subject of the complaint and has no  
material conflict of interest;  
Ensure that students and other complainants are not penalised for making a complaint in good  
faith;  
Maintain a confidential written record of every formal complaint, actions, outcomes and reasons,  
regardless of whether upheld; retain records for at least three years, subject to the approved Data  
Retention Schedule and any necessary safeguarding or legal hold;  
Review complaint records, recurring themes and resulting improvements regularly at  
management level;  
Limit access to complaints information to authorised personnel and share it only where necessary  
and lawful;  
Nominate Yuexuan Wang (Sunny) to maintain the central formal Complaints Register, except  
where the complaint is about Sunny or a conflict exists. An alternative authorised officer will then  
maintain the confidential case record.  
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PROCEDURE  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Stage 1: Informal Stage  
An informal concern can be raised in person, by telephone, email or in writing, including through a  
representative with appropriate authority. The normal first point of contact is Yuexuan Wang (Sunny),  
Guardianship Coordinator, on 07743 386699 or gd3@compassedu.co.uk. If the concern relates to  
Sunny, contact Director Lu Jin (Lucy) instead. If it relates to Lucy, contact Annie Swynnerton  
(Guardianship Lead) directly. The recipient will:  
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Record the concern, agreed next steps and actions taken;  
Acknowledge it within 24 hours during normal working arrangements, or by the next working  
day if received outside office hours;  
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Make appropriate enquiries and work towards an agreed resolution;  
Provide an update or outcome within seven working days, or explain the reason for a delay  
and when a further response will follow.  
If the matter remains unresolved, or is serious enough to require formal consideration, the  
complainant may proceed directly to Stage 2.  
Stage 2: Formal Stage  
A formal complaint should be submitted in writing, identifying the concern, relevant dates and the  
outcome sought. In the normal course, it should be addressed to Yuexuan Wang (Sunny) at  
gd3@compassedu.co.uk. If the complaint concerns Sunny, it must instead be addressed to Director Lu  
Jin (Lucy) at Hertslucy@gmail.com (telephone 07912 847858). If the complaint concerns Lucy, it  
should be submitted directly to Annie Swynnerton, Guardianship Lead, at annie@compassedu.co.uk  
(telephone 07958 718598). The person complained about must not investigate or determine their own  
complaint. Where impartial internal handling cannot be secured, the complainant may seek guidance  
or refer an unresolved matter to AEGIS. The responsible complaint handler will:  
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Log the formal complaint and the date received in a restricted Complaints Register,  
including the complainant and subject matter;  
Acknowledge receipt within 24 hours during normal working arrangements, or by the  
next working day if received outside office hours, and confirm the investigator;  
Investigate fairly, hear relevant accounts, maintain confidentiality, record evidence,  
decisions and actions, and keep the complainant informed of material progress;  
Provide a written decision, reasons, any remedy or action to be taken, and details of  
further escalation within 28 working days, or give a justified revised timescale where  
exceptionally necessary;  
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Record the outcome and follow-up action whether the complaint is upheld, partly  
upheld or not upheld. If unresolved after the internal process, explain how to contact  
AEGIS (Stage 3).  
Stage 3: Referral of the matter to AEGIS  
If the complaint cannot be resolved by Compass, or impartial handling within Compass is not possible,  
the complainant may refer the matter to AEGIS, explaining the concern, steps taken, outcome and any  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
relevant AEGIS Quality Standards. AEGIS will handle the matter under its own Complaints Policy, which  
may require completion of its complaints form. Compass will cooperate with any appropriate  
independent consideration.  
AEGIS – Association for the Education and Guardianship of International Students  
Chief Executive Officer: Yasemin Wigglesworth  
The Wheelhouse, Bond’s Mill Estate, Bristol Road, Stonehouse, Stroud, Gloucestershire GL10 3RF  
Telephone: +44 (0)1453 821293 | Email: info@aegisuk.net  
CHILD SAFEGUARDING AND URGENT CONCERNS  
A complaint involving a child protection concern, alleged abuse, serious risk of harm, an allegation against an  
adult, or an immediate welfare emergency must be handled without delay under Compass’s Safeguarding and  
Child Protection Policy. It must not wait for the seven- or 28-working-day complaints timescales. The Designated  
Safeguarding Lead (DSL) or Deputy DSL must be informed promptly and, where required, children’s social care,  
the LADO, police or emergency services contacted. Call 999 if a child is in immediate danger. The 24-hour  
emergency contact is 07912 847858 (Lucy), with escalation to the DSL or Deputy DSL.  
ACCESSIBILITY, CONFIDENTIALITY AND RECORD KEEPING  
Students and families may ask for an explanation of this procedure in clear and age-appropriate language,  
including Chinese language support where reasonably available. Complaints may be made in person or remotely.  
Compass will make reasonable adjustments and seek an appropriate interpreter where needed, without  
requiring a child to rely on a person about whom they are complaining.  
Each formal record should state the date and method received; complainant and student (where relevant);  
nature of the concern; person assigned; key evidence and correspondence; actions, decisions and reasons; date  
and substance of each response; outcome (including whether upheld); remedy and follow-up; and any referral  
to AEGIS or safeguarding authorities. The records will be stored securely with access restricted to authorised  
staff. Complaints about Sunny or Lucy must be stored so the subject of the complaint does not have  
inappropriate access to the confidential investigation.  
REVIEW  
Compass will review this policy at least annually and following significant complaints or safeguarding lessons.  
The current approved version of this policy is made publicly available on the Compass website.
Version: 2026 – Version 1.0  
Previous Review Date: 23 August 2025  
Review Date: 23 August 2026  
Effective Date: 23 October 2026  
Next Review Date: 23 October 2027  
Approved by: Lu Jin (Lucy)  
Position: Director  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Signature: ________Lu Jin__________________  
Date Approved: 23 October 2026  
Registered in England No. 9024815